GIN Network Truth (the smart group)docshare01.docshare.tips/files/18516/185163558.pdf · GIN Network Truth (the smart group) 6 15. The Receiver has also reviewed records relating

GIN Network Truth (the smart group)

UNITED STATES DISTRICT COURT FOR

THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

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Case No.: 03-C-3904

Hon. Robert W. Gettleman

RECEIVER’S FIRST MOTION FOR

INTERIM APPROVAL OF FEES AND EXPENSES

Robb Evans & Associates, LLC (the “Receiver”), in its capacity as court-appointed

receiver over the assets of Kevin Trudeau and the Trudeau Entities, respectfully submits this first

interim fee application seeking approval to pay fees and expenses of the Receiver and

professionals retained by the Receiver, including the law firm Hiltz Wantuch & Zanzig LLC

(“HWZ”). In this application, the Receiver seeks approval of fees and expenses incurred during

the first two months of the receivership, from August 7, 2013, through September 30, 2013 (the

“First Interim Period”). In further support of its motion, the Receiver states as follows:

BACKGROUND

1. On August 7, 2013, the Court entered the Order Appointing a Receiver and

Implementing Ancillary Relief [Dkt. # 742] (the “Receivership Order”) appointing Robb Evans

& Associates LLC as receiver over the assets of Defendant Kevin Trudeau (“Trudeau”), the

Trudeau Entities, and any affiliates or subsidiaries thereof controlled by Trudeau or any Trudeau

Case: 1:03-cv-03904 Document #: 790 Filed: 11/15/13 Page 1 of 11 PageID #:14190


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Entity.1 In appointing the Receiver, the Court adopted the FTC’s recommendation that any such

receiver should be a forensic accountant with asset-tracing experience.

2. Under the Receivership Order, the Receiver was authorized to retain attorneys and

other professionals as the Receiver deemed advisable or necessary in the performance of the

Receiver’s duties. (Receivership Order at § V(6).) Pursuant to such authority, the Receiver

retained the law firm of Hiltz Wantuch & Zanzig LLC (“HWZ”) to represent the Receiver and

assist it in carrying out its duties in the matter.

3. As detailed below, for the First Interim Period of August 7, 2013, through

September 30, 2013, the Receiver presently seeks approval of its professional fees in the total

amount of $289,405.40, and out-of-pocket expenses totaling $17,869.92, including travel-related

expenses. Additionally, the Receiver seeks authority to pay legal fees incurred during the First

Interim Period by HWZ totaling $42,486.

4. Pursuant to the terms of the Receivership Order, the Receiver and its

professionals, are entitled to reasonable compensation for the performance of duties undertaken

pursuant to this order and for the cost of actual out-of-pocket expenses they incur. (Receivership

Order § XII(1).) If approved, such compensation is to be paid first from assets recovered

pursuant to the Receivership Order, and then, if necessary, from the “Escrow Account” described

in the Receivership Order. (Id. at § XII(4) & (5).) As reflected in the financial report

accompanying the Receiver’s Second Supplemental Report [Dkt. #785], which is re-attached

here for the parties’ convenience as Exhibit A, as of September 30, 2013, before applying

Receivership fees and expenses, the Receiver recovered net proceeds of approximately $2.7 MM

1 Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the

Receivership Order.



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including $1,512,077.07 from operating the Receivership entities, exclusive of $486,854.80 in

reserves held by the receivership estate’s credit card processor.

5. Accordingly, the Receiver has more than sufficient funds to pay the professional

fees and expenses, including legal fees, requested herein from assets recovered pursuant to the

Receivership Order, without needing to draw on the Escrow Account. Indeed, even after

applying all professional fees and expenses, the receivership estate will still have a net balance of

nearly $1 million. (See Ex. A.)

OVERVIEW OF RECEIVER’S ACTIVITIES AND FEES

6. The Receiver filed its First Report on September 6, 2013, in which it detailed its

activities from the time of its appointment through September 5, 2013. The Receiver submitted

its First Supplemental Report on September 16, 2013, detailing, among other things, (a) its

discovery of the Australian bank account held at St. George Bank Ltd., and (b) its initial analysis

of certain bank records for GIN-FDN, including post-receivership transfer to Trudeau’s wife’s

bank account in Antigua. Following the submission of those reports, the Receiver participated in

a number of hearings before the Court in which the Receiver further updated the Court on the

Receiver’s ongoing activities. On October 25, 2013, the Receiver filed its Second Supplemental

Report in which it updated the Court on the financial condition of the receivership estate from

the inception of the receivership through September 30, 2013.

7. In addition, the Receiver has maintained detailed records of the billable time it has

devoted to this matter and for which it is now seeking authority to pay. Attached as Exhibit B to

this application are comprehensive invoices prepared by the Receiver (and redacted for privilege)

setting forth the specific tasks performed and the time spent performing those tasks by the

Receiver’s timekeepers.



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8. As reflected in more detail in its reports to the Court and the attached detailed

invoices, the Receiver provides the following overview of its activities during the First Interim

Period:

9. During the first two months of the receivership, the Receiver assumed control of

numerous Trudeau Entities located in the United States as well as certain of the personal assets

of Trudeau. The Receiver has further sought to exert control over the remaining Trudeau

Entities located overseas, and investigate and identify the existence of any as yet undisclosed

assets.

10. As part of assuming control over the various Trudeau Entities, the Receiver has

conducted a top to bottom review of those entities’ operations, including their accounting and

payroll functions. In the course of that review, the Receiver has met with current management

and staff, and reviewed the books and records of the companies. The Receiver has sought to

minimize expenses, including reducing staffing levels to correspond to the Trudeau entities

ongoing needs. The Receiver cancelled a previously planned cruise for GIN members after

determining that the companies’ lack sufficient funding to finance the event. The Receiver

approved the expenditure of $340,000 to fund initial expenses for a pre-planned membership

event in Washington D.C. that the Receiver anticipates it will recover from the proceeds from

such event. The Receiver continues to oversee management’s operation of the Trudeau Entities.

11. Mindful of the Court’s direction in the Receivership Order that the Receiver may

only continue and conduct the business of any of the Trudeau Entities to the extent it is possible

to operate such business legally, the Receiver has continued to review the legality of such

businesses and has commenced tailoring the Trudeau Entities’ operations accordingly. For

example, the Receiver has begun the process of causing the Trudeau Entities to remove false and



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misleading claims from its websites. As reflected in its First Report, the Receiver is continuing

to work on a marketing plan that can be operated lawfully. As provided by the Receivership

Order, if the Receiver determines that a Trudeau Entity cannot be operated legally, the Receiver

will promptly notify the Court and parties and seek the Court’s permission to terminate the

entity’s respective operations.

12. Soon after assuming control of the various domestic Trudeau Entities, the

Receiver determined that credit card payments from their consumers were being routed to an

overseas accounts located in the Isle of Man. The Receiver took steps to cause a domestic credit

card processor to take over such transactions and deposit the proceeds in a domestic bank

account. Through these actions, excluding reserve amounts retained by the credit card processor,

the Receiver has captured in excess of $1.4 million in credit card charges that otherwise would

have been transferred off-shore.

13. The Receiver has also met with Trudeau and his counsel on numerous occasions

to coordinate the turnover of known receivership assets and to further identify and investigate the

possible existence of any other assets. The Receiver has taken steps to terminate the lease

relating to the White Oak Property and assume control of Trudeau’s possessions therein. The

Receiver has also taken control over Trudeau’s real property located in Ojai, California and the

related sale process.

14. As directed by the Receivership Order, and after soliciting the input of both

Trudeau and the FTC, the Receiver prepared a necessary and ordinary living expenses budget for

Trudeau and administered that budget until the Court terminated such allowance in its September

26, 2013 Order [Dkt. #760] granting the FTC’s motion to modify the Receivership Order.



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15. The Receiver has also reviewed records relating to Trudeau’s legal defense fund

and coordinated the transitioned the administration of such fund to Trudeau’s present counsel.

16. In connection with its investigation of the existence of other undisclosed assets,

the Receiver has obtained and analyzed records from Marc Lane, Trudeau’s former “asset

protection advisor.”

17. During the First Interim Period, the Receiver also attempted to coordinate with

Lee Kenny, a close associate of Trudeau who appears to nominally control GIN-FDN from

England. As reported in the Receiver’s first report, Lee Kenny had promised the production of

all accounting records related to GIN-FDN, but, until more recently, had only produced certain

bank statements.

18. The Receiver has also served the Receivership Order on various financial

institutions at which the Trudeau Entities appeared to hold accounts. The Receiver assumed

control over such accounts and requested relevant banking records to facilitate an analysis of the

flow of funds into and out of such accounts. Using information obtained from such records, the

Receiver also coordinated with its counsel to issue subpoenas for bank records of third parties

that appear to have received substantial funds from the Trudeau Entities.

19. During the First Interim Period, the Receiver also attended multiple hearings

before the Court addressing Trudeau’s failure to fully cooperate with the Receiver and otherwise

violate the Court’s prior orders. On September 18, 2013, the Court found Trudeau in contempt

ordering him coercively incarcerated. The Court directed the Receiver to interview Trudeau at

the Metropolitan Correctional Center that evening and report back to the Court the following

day. On September 19, 2013, the Receiver appeared before the Court and reported on the results

of its interview and additional investigation. The Court directed Trudeau to be released and set a



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status hearing for the following week, requiring the Receiver to again report on Trudeau’s

compliance with the Receiver’s instructions during the interim. The Receiver met and

correspond with Trudeau through the following week. On September 26, 2013, the Receiver

again appeared before the Court to report on the activities of the preceding week. As a result of

the events related to these hearing, the Receiver (with its counsel) devoted an intense effort to

preparing for each hearing, attempting to solicit Trudeau’s cooperation, and following up on any

new information provided. Throughout, the Receiver and its counsel also coordinated with the

FTC so as to draw upon the FTC’s familiarity with the substantial evidentiary record in this case.

20. During the First Interim Period, the Receiver’s personnel collectively devoted

1,048.1 hours to this matter, incurring fees totaling $289,405.40, for an effective blended rate of

approximately $276 per hour. The principal members of the Receiver’s firm and senior

associates working on this matter billed at an hourly rate of $301.50. All of the fees charged by

the Receiver in this matter reflect a 10% discount from the firm’s private sector rates. As

required by the Receivership Order, the compensation sought in this motion is consistent with

the rate structure and terms outlined in Exhibit 1 of the FTC’s Statement With Respect to the

Appointment of a Receiver [Dkt. #730]. (See Receivership Order § XII(2).)

21. In addition to the professional fees sought by the Receiver, the Receiver has also

incurred $17,869.92 in out-of-pocket expenses. The vast majority of these expenses are costs

associated with travel by the Receiver’s personnel to Chicago during August 2013 to meet with

Trudeau and visit the Trudeau Entities’ facilities in Westmont, Illinois in order to effect control

over those entities and meet with the Trudeau Entities’ staff and management. Such travel

expenses total $16,352.68.The remaining expenses for which the Receiver seeks reimbursement



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are as follows: $582.82 for investigative search costs; $149.05 for office telephone and supplies;

$653.80 for postage and delivery expenses; $131.57 for subpoena and document reproduction.

OVERVIEW OF LEGAL SERVICES AND FEES

22. Receiver’s counsel maintained detailed records of the billable time for which the

Receiver now seeks authority to pay. Attached as Exhibit “C” to this Motion is a comprehensive

invoice prepared by HWZ (and redacted for privilege) setting forth the specific tasks performed

and the time spent performing those tasks by HWZ’s timekeepers.

23. As reflected in the detailed invoice, during the First Interim Period, HWZ

provided the following services to the Receiver:

Advised the Receiver concerning its authority and obligations under the

Receivership Order.

Assisted the Receiver in preparing an ordinary and necessary living expense

budget provided for under the Receivership Order, including advising the

Receiver regarding comparable standards used by IRS and under Bankruptcy

Code.

Advised Receiver regarding FTC’s motion to modify the Receivership Order to

deny Trudeau living expense budget.

Advised Receiver regarding rights in connection with Oak Park Property,

including corresponding with counsel for owner of Oak Park Property to

designated property as “Business Premises” under Receivership Order.

Advised Trustee in connection interference by L. Kenny with Receiver’s control

of GIN-FDN.

Assisted the Receiver in revising, finalizing and filing the Receiver’s First Report

and two supplemental reports.

Prepared and served on the Receiver’s behalf seven subpoenas to various

financial institutions seeking to locate assets or potential assets of the receivership

estate.

Prepared and filed various pleading regarding imposition of coercive sanctions,

including responses to statements filed by FTC and Trudeau.



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Attended multiple hearings before the Court in connection with imposition of

coercive sanctions and subsequent hearings affording Trudeau opportunity to

purge contempt.

Advised and assisted Receiver in preparing for and interviewing Trudeau

regarding disposition of potential assets of the receivership, including interview

conducted during Trudeau’s incarceration.

Advised Receiver regarding responses to various entities asserting claims against

receivership estate for pre-receivership obligations.

24. During the two months comprising the First Interim Period, HWZ’s professionals

expended 118.6 hours on this matter. Blair Zanzig, one of HWZ’s members, was principally

responsible for providing these services. Mr. Zanzig is an experienced attorney with expertise in

complex civil litigation who has represented receivers in similar matters. For the services outline

above and as detailed in the attached invoices, HWZ has invoiced the Receiver for fees totaling

$42,486. For similar matters, Mr. Zanzig ordinarily bills $400 an hour, but in recognition of the

interests of consumers in this case, HWZ has agreed to discount such rate by 10%. Thus, HWZ’s

invoice reflects an effect rate of $360 per hour for attorney time and $150 per hour for

administrative/paralegal tasks. The Receiver believes these rates are comparable, if not less than,

those the Receiver has seen in connection with other comparable matters.

WHEREFORE, Receiver respectfully requests the Court enter an Order (a) approving

the fees and expensesincurred by the Receiver Robb Evans & Associates LLC for the First

Interim Period in the amount of $307,275.30; (b) approving the legal fees incurred by Receiver’s

counsel Hiltz Wantuch & Zanzig LLC for the First Interim Period in the amount of $42,486; (c)

authorize the Receiver to immediately pay all such approved fees and expenses from funds held



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by the Receiver; and (d) grant the Receiver such further relief as the Court deems just and

proper.

Dated: November 15, 2013 Respectfully submitted,

ROBB EVANS & ASSOCIATES LLC,

RECEIVER

By: /s/ Blair Zanzig

(One of Its Attorneys)

Blair R. Zanzig (No. 6273293)

John F. Hiltz (No.6289744)

Kathy Wantuch (No. 6294034)

HILTZ WANTUCH & ZANZIG LLC

53 West Jackson Blvd., Suite 205

Chicago, Illinois 60604

Telephone: 312.566.9008

Fax: 312.566.9015

Counsel for Robb Evans & Associates, Receiver



CERTIFICATE OF SERVICE

I, Blair R. Zanzig, an attorney, hereby certify that, on the 15thday of November, 2013, I

caused a true and correct copy of the foregoing Receiver’s First Motion For Interim Approval of

Fees and Expenses to be served through the Court’s Electronic Case Filing System on the

following:

Kimball Richard Anderson

[email protected]

Thomas Lee Kirsch, II

[email protected]

Katherine E. Rohlf

[email protected]

Michael Mora

[email protected]

Jonathan Cohen

[email protected]

Amanda B. Kostner

[email protected]

David O’Toole

[email protected]

/s/ Blair R. Zanzig


mailto:[email protected]








EXHIBIT A

Case: 1:03-cv-03904 Document #: 790-1 Filed: 11/15/13 Page 1 of 5 PageID #:14201


ROBB EVANS ASSOCIATES LLCReceiver of

The Assets of Kevin Trudeau, the Trudeau Entities, et al. Administrative Expenses and Fund Balance

From Inception (August 7, 2013) to September 30, 2013

Aug 31, 13 Sep 30, 13 TOTAL

Corporate Account FundsGlobal Information Network 225,000.00 0.00 225,000.00Global Info Network Foundation 0.00 262,116.42 262,116.42I-Payout Systems Inc. 2,687.11 0.00 2,687.11K.T. Corporation Limited 2,617.02 0.00 2,617.02Natural Cures Health Insurance 0.00 50,304.26 50,304.26Natural Cures Inc.

Baytree National B&T 30,618.28 0.00 30,618.28Cardflex Payment Solutions Inc. 35,880.20 0.00 35,880.20Meritus Payment Solutions 0.00 0.00 0.00National Bank of California 78,134.57 0.00 78,134.57

Total Natural Cures Inc. 144,633.05 0.00 144,633.05

Tru-Com LLC 804.01 0.00 804.01Trudeau Approved Products 101,377.04 0.00 101,377.04Trustar Productions Inc. 1,376.72 0.00 1,376.72Website Solutions USA 422,249.48 0.00 422,249.48

Total Corporate Account Funds 900,744.43 312,420.68 1,213,165.11

Incoming ReceiptsGlobal Information Network

Receiver AccountCopyright Royalties 0.00 9,374.88 9,374.88Event Commissions 0.00 2,426.25 2,426.25Membership Dues & Upgrades-Chk 7,975.00 21,267.81 29,242.81Membership Dues & Upgrades - CC

Credit Card Charges 663,484.95 1,270,082.49 1,933,567.44Reserves Balance - Funds Not Available (212,272.47) (273,369.39) (485,641.86)Refunds (1,350.00) (4,750.00) (6,100.00)Chargebacks (600.00) (2,507.81) (3,107.81)

Total Membership Dues & Upgrades - CC 449,262.48 989,455.29 1,438,717.77

Total Receiver Account 457,237.48 1,022,524.23 1,479,761.71

Non-Receiver AccountRemote Deposit 8,633.85 4,627.30 13,261.15

Total Non-Receiver Account 8,633.85 4,627.30 13,261.15

Total Global Information Network 465,871.33 1,027,151.53 1,493,022.86

Trudeau Approved ProductsReceiver Account

Credit Card SalesCredit Card Charges 0.00 5,497.88 5,497.88Reserves Balance - Funds Not Available 0.00 (1,212.94) (1,212.94)Chargebacks 0.00 (199.85) (199.85)Refunds 0.00 (646.05) (646.05)

Total Credit Card Sales 0.00 3,439.04 3,439.04

Total Receiver Account 0.00 3,439.04 3,439.04

Page 1 of 4







Non-Receiver AccountBankcard MTOT Dep 6,547.61 0.00 6,547.61SBC VSMC Deposits 5,316.42 3,751.14 9,067.56

Total Non-Receiver Account 11,864.03 3,751.14 15,615.17

Total Trudeau Approved Products 11,864.03 7,190.18 19,054.21

Total Incoming Receipts 477,735.36 1,034,341.71 1,512,077.07

Interest Income 2.57 76.24 78.81Miscellaneous Income 1,003.65 0.00 1,003.65

Total Funds Collected 1,379,486.01 1,346,838.63 2,726,324.64

ExpenseBusiness Operation Expenses

Alarm & Security 0.00 105.00 105.00Bank Fees 141.07 180.71 321.78Cellular Services 0.00 0.00 0.00Colocation Server Services 0.00 5,050.00 5,050.00Contest Winner Vehicle Lease 7,250.00 7,250.00 14,500.00Credit Card Discounts & Fees

Verifi 170.35 97.60 267.95NMC 0.00 17,721.04 17,721.04Meritus Merchant 19.95 19.95 39.90Authnet Gateway Fees 79.00 1,527.55 1,606.55GIN CC Discounts 33,174.25 63,504.13 96,678.38Trudeau App Product CC Discount 518.34 1,413.08 1,931.42

Total Credit Card Discounts & Fees 33,961.89 84,283.35 118,245.24

Document Destruction Services 0.00 290.80 290.80Electricity 1,587.89 1,482.30 3,070.19Employer Payroll Taxes 12,188.79 9,860.16 22,048.95Equipment Rental 0.00 520.34 520.34Exigo Services 0.00 12,500.00 12,500.00Event Management Fees 0.00 100,000.00 100,000.00Gift Cards 0.00 215.35 215.35G.I.N. Commission Payments 0.00 258,000.00 258,000.00GIN Family Reunion Event Exp 0.00 340,239.70 340,239.70Health Insurance & Benefits 0.00 47,337.35 47,337.35Independent Contractor Fees 31,352.08 13,305.00 44,657.08Intercompany Payroll Allocation 7,200.00 0.00 7,200.00Inventory Disposal/Shredding 0.00 0.00 0.00Inventory Storage 72.68 525.00 597.68Janitorial Services 610.00 3,475.00 4,085.00Locksmith Services 0.00 251.90 251.90Member/Affiliate Communications 0.00 0.00 0.00Natural Gas 200.73 254.78 455.51Office Rent 0.00 22,164.16 22,164.16Office Supplies 0.00 418.44 418.44

Page 2 of 4







Payroll Expenses 166,500.10 134,115.48 300,615.58Payroll Processing Fees 452.10 411.10 863.20Phone & Internet Services 755.28 2,776.41 3,531.69Prior Period CC Return 300.00 150.00 450.00Promotional Expenses 5,000.00 96.80 5,096.80Sales & Use Taxes 27.36 0.00 27.36Security Services 960.00 0.00 960.00Shipping & Packaging 3,715.64 5,678.51 9,394.15Software Support Service 0.00 3,894.00 3,894.00Transportation Services 0.00 772.59 772.59Travel Expenses 2,130.53 2,848.02 4,978.55Unspecified Business Expenses 0.00 0.00 0.00Website Services 2,253.51 1,452.57 3,706.08

Total Business Operation Expenses 276,659.65 1,059,904.82 1,336,564.47

Ojai, CA Residential PropertyElectricity 0.00 1,303.22 1,303.22Landscaping Maintenance 0.00 1,121.83 1,121.83Natural Gas 0.00 280.83 280.83Pool Maintenance 0.00 120.00 120.00Security & Caretaking 0.00 4,358.98 4,358.98Water 0.00 1,299.81 1,299.81

Total Ojai, CA Residential Property 0.00 8,484.67 8,484.67

Payment to Winston & Strawn LLP 0.00 33,128.28 33,128.28Kevin Trudeau Living Expense 4,676.00 4,676.00 9,352.00Receiver Fees & Expenses

Receiver FeesReceiver

R. Evans 535.50 38.25 573.75B. Kane 17,245.80 14,502.15 31,747.95K. Johnson 35,697.60 29,607.30 65,304.90V. Miller 28,401.30 1,326.60 29,727.90A. Jen 22,612.50 17,456.85 40,069.35

Total Receiver 104,492.70 62,931.15 167,423.85

Senior StaffL. Lee 14,984.55 6,030.00 21,014.55T. Chung 18,301.05 14,954.40 33,255.45F. Jen 21,617.55 25,506.90 47,124.45C. Callahan 2,992.50 3,397.50 6,390.00E. Roop 3,064.50 0.00 3,064.50C. DeCius 801.00 7,335.00 8,136.00N. Wolf 30.00 0.00 30.00J. Dadbin 0.00 819.50 819.50

Total Senior Staff 61,791.15 58,043.30 119,834.45

Support Staff 545.00 1,602.10 2,147.10Total Receiver Fees 166,828.85 122,576.55 289,405.40

Page 3 of 4







Receiver ExpensesBank Fees 0.00 0.00 0.00Investigative Search Costs 452.00 130.82 582.82Office Telephone & Supplies 0.00 149.05 149.05Postage & Delivery 95.26 558.54 653.80Subpoena/Document Reproduction 22.00 109.57 131.57Travel Expenses 16,352.68 0.00 16,352.68

Total Receiver Expenses 16,921.94 947.98 17,869.92

Legal Fees & CostsLegal Fees 15,912.00 26,424.00 42,336.00Legal Costs 0.00 150.00 150.00

Total Legal Fees & Costs 15,912.00 26,574.00 42,486.00

Total Receiver Fees & Expenses 199,662.79 150,098.53 349,761.32

Total Expense 480,998.44 1,256,292.30 1,737,290.74

Fund Balance 898,487.57 90,546.33 989,033.90

Page 4 of 4



EXHIBIT C



TO:

ROBB EVANS & ASSOCIATES, LLC

Receiver of the Assets of Kevin Trudeau et al.

11450 Sheldon Street

Sun Valley, California 9L352-L72L

HTLTZ WANTUCH & ZANZIG

SUMMARY

INVOICE NO: 1081

SEPTEMBER 25,2013

PAYMENT DUE UPON RECEIPT

s17,680

-5L,768

S15,912

FEE FOR PROFESSIONAL SERVICES

RENDERED PER ATTACHED DETAIL

LESS 10% DISCOUNT IN

RECOGNITION OF PUBLIC

INTERESTS

TOTAL CURRENT AMOUNT DUE


GIN Network Truth (the smart group) INVOICE NO: 1081

SEPTEMBER 25,2013PAYMENT DUE UPON RECEIPT

DETAIL

Date TMK Description of Services Rendered Time

8/L2/20t3 BRZ

REVIEWED DOCKET, HEARING TRANSCRIPTS AND RELATED

BACKG ROU ND DOCUM ENTS REGARDI NG TRUDEAU RECEIVERSH IP.

CONFERRED WITH B. KANE REGARDING .

REVIEWED MATERIALS AND FOLLOW-UP TELEPHONE CONFERENCE

RELATED TO SAME. RESEARCHED APPLICABLE IRS AND BANKRUPTCY

STANDARDS FOR LIVING EXPENSES. CONFERRED WITH K. WANTUCH

AND J. HILTZ REGARDING SAME. REVIEWED LIVING EXPENSE

BUDGET PROPOSED BY K. TRUDEAU. CONFERRED WITH B. KANE

AND K. JOHNSON REGARDING SAME. REVIEWED CORRESPONDENCE

FROM FTC AND K. TRUDEAU'S COUNSEL REGARDING SAME.

8.7

8/L3/2Or3 BRZ

TELEPHONE CALL WITH J. COHEN REGARDING CASE STATUS AND

RELATED MATTERS. TELEPHONE CONFERENCE WITH B. KANE AND K'

JOHNSON REGARDING SAME AND GIN PROCESSING CHARGES.

REVIEWED KEY PLEADING RELATING TO RECEIVERSHIP. DRAFTED

PROPOSED ORDINARY AND NECESSARY LIVING EXPENSE BUDGET.

7.8

8lt4/2OL3 BRZ

CONFERRED WITH K. WANTUCH REGARDING K. TRUDEAU LIVING

EXPENSE BUDGET

MET WITH B. KANE AND K. JOHNSON REGARDING K'

TRUDEAU LIVING EXPENSE BUDGET. ANALYZED AND RECONCILED

BUDGETS PROPOSED BY K. TRUDEAU AND RECEIVER. RESEARCHED

APPLICABLE STANDARDS.

5.2

8/t4/2OL3 KW

REVIEWED PROPOSED LIVING EXPENSE BUDGET FOR K. TRUDEAU.

CONFERRED WITH B. ZANZIG REGARDING .4

8/15l2OL3 BRZ

REVIEWED CORRESPONDENCE FROM FTC REGARDING L. KENNY

INTERFERENCE WITH RECEIVER,S OPERATION OF GIN FOUNDATION.

TELEPHONE CALL WITH J. COHEN REGARDING SAME.

CORRESPONDED WITH B. KANE AND K. JOHNSON REGARDING SAME.

1.8



SEPTEMBER25,2OT3PAYMENT DUE UPON RECEIPT


8/Le/2Ot3 BRZ

REVIEWED SUBPOENA ISSUED BY FTC TO KOBRA & KIM.

CORRESPONDED WITH B. KANE REGARDING MESSAGE TO GIN

M EM BERS/EM PLOYEES REGARDING L. KEN NY PARTICIPATION.

REVIEWED CORRESPONDENCE WITH K. TRUDEAU REGARDING

LIVING EXPENSE BUDGET. ADVISED RECEIVER REGARDING SAME

AND REGARDING REQUEST TO K. TRUDEAU TO DIRECT L. KENNY

COOPERATION. TELEPHONE CALL WITH FTC REGARDING CASE

STATUS AND RELATED ISSUES. DRAFTED LETTER TO K. TRUDEAU

COUNSEL REGARDING SAME.

4.t

8l2O/2013 BRZ

REVIEWED SWORN FINANCIAL STATEMENT PROVIDED BY K.

TRUDEAU COUNSEL. CONFERRED WITH B. KANE REGARDING OAK

PARK PREMISES AND NOTICE TO TREAT AS BUSINESS PREMISES.

DRAFTED NOTICE LETTER. REVIEWED CORRESPONDENCE

REGARDING OBJECTIONS BY FTC TO K. TRUDEAU LIVING EXPENSE

BUDGET. ADVISED RECEIVER REGARDING SAME.

4.2

8/27/20t3 BRZ

DRAFTED LETTER TO L. KENNY REGARDING TERMINATION OF

CONTINUED EMPLOYMENT AND RELATED MATTERS. CONFERRED

WITH B. KANE AND K. JOHNSON REGARDING SAME. PREPARED AND

FILED APPEARANCE ON BEHALF OF RECEIVER. FINALIZED NOTICE

LETTER REGARDING WHITE OAK PROPERTY. TELEPHONE

CONFERENCE WITH J. COHEN REGARDING CASE STATUS.

6.8

8/22/2013 BRZREVIEWED CORRESPONDENCE REGARDING L. KENNY COOPERATION.

ADVISED RECEIVER REGARDING SAME..6

8/26/2073 BRZ

CORRESPONDED WITH B. KANE AND K. JOHNSON REGARDING

RECEIVER,S FIRST REPORT. TELEPHONE CONFERENCE WITH J.

COHEN REGARDING SAME AND RELATED ISSUES.

7.4

8/28120L3 BRZ

REVIEWED DRAFT PLEADINGS RELATED TO K. TRUDEAU LIVING

EXPENSES. TELEPHONE CONFERENCE WITH A. JEN REGARDING A.

GORDON TAX LAWYERS. REVIEWED RELATED CORRESPONDENCE.

.8

8/2s/2Ot3 BRZCONFERRED WITH A. JEN REGARDING DIRECTIONS TO K. TRUDEAU

TAX LAWYERS..4

8/30/2013 BRZREVIEWED AND ANALYZED FTC MOTION TO MODIFY RECEIVERSHIP

ORDER. TELEPHONE CONFERENCE WITH FTC REGARDING SAME.1.6



SEPTEMBER 25,2013PAYMENT DUE UPON RECEIPT

Time and Fee Summary:

Timekeeper Hours Rate Fee Value

Blair R. Tanzie 43.8 s400 sL7,52O

Kathv Wantuch .4 s400 s15oTOTAL 44.2 s17,680



HILTZWANTUCH &ZANZIG

TO:

ROBB EVANS & ASSOCIATES, LLCReceiver of the Assets of Kevin Trudeau et al.11450 Sheldon StreetSun Valley, California 9L3SZ-LL}L

INVOICE NO:1082ocToBER 7,20t3


s29,360

-s2,936

Srso

526,s74

SUMMARY

FEE FOR PROFESSIONAL SERVICES

RENDERED PER ATTACHED DETAIL

LESS 10% DISCOUNT INRECOGNITION OF PUBLIC

INTERESTS

COSTS AND ADMINISTRATIVEEXPENSES PER ATTACHED DETAIL

TOTAT CURRENT AMOUNT DUE


GIN Network Truth (the smart group) |NVOICE NO: 1082ocToBER 7,20t3


DETAIT

Description of Services Rendered

TELEPHONE CALL WITH B. KANE AND K. JOHNSON REGARDING. TELEPHONE CONFERENCE WITH J.

COHEN REGARDING VARIOUS CONCERNS OF FTC IMPLICATINGRECEIVER.

e/s/20L3

RESEARCHED RECEIVER'S AUTHORITY TO ASSERT CONTROL OVER K.TRUDEAU HUSHMAIL ACCOUNT AND RELATED PROCEDURES.CORRESPONDED WITH B. KANE AND K. JOHNSON REGARDINGSAME. CORRESPONDED WITH B. KANE AND K. JOHNSONREGARDING

REVIEWED AND REVISED RECEIVER'S FIRST REPORT. CONFERREDWITH B. KANE AND K. JOHNSON REGARDING . COORDINATEDFILING OF RECEIVER'S FIRST REPORT.

TELEPHONE CONFERENCE WITH A. GORDON REGARDING RETAINERRECEIVED FROM K. TRUDEAU. CORRESPONDED WITH A. JENREGARDING CORRESPONDED WITH B. KANE AND K.JOHNSON REGARDING

REVEIWED CORRESPONDENCE FROM GIN MEMBERS.

9/rtl2073

CORRESPONDED WITH B. KANE AND K. JOHNSON REGARDING

DRAFTED LETTER TO GORDON LAW GROUP REGARDING RETURNOF RETAINER.

9112/2013

FINALIZED LETTER TO GORDON LAW GROUP REGARDINGRETAINER. DRAFTED SUBPOENA RIDER SEEKING BANK RECORDS.CORRESPONDED WITH B. KANE AND A. JEN REGARDING REVIEWED RECEIVER'S CORRESPONDENCE WITH K. TRUDEAUREGARDING ST. GEORGE BANK ACCOUNT.

9/L6/2013

TELEPHONE CONFERENCE WITH P. DEADY AND D. DONNELLONREGARDING PRE-RECEIVERSHIP ATTORNEY FEE CLAIMS. REVIEWEDAND REVISED RECEIVER'S SUPPLEMENTAL REPORT.CORRESPONDED WITH B. KANE AND K. JOHNSON REGARDING

COORDINATED FILING OF SUPPLEMENTAL REPORT.DRAFTED CEASE AND DESIST LETTER REGARDING SOCIAL MEDIAPOSTS BY CERTAIN GIN MEMBERS.


GIN Network Truth (the smart group) |NVO|CE NO: 1082ocToBER 7,2013



e/17120L3 BRZ

FINALIZED CEASE AND DESIST LETTERS REGARDING SOCIAL MEDIA.CORRESPONDED WITH LESSOR OF OAK PARK PROPERWREGARDING SALE OF PERSONAL PROPERW.

.6

e/78/20L3 BRZ

PREPARED FOR HEARING ON RECEIVER'S FIRST REPORT AND FTCMOTION TO MODIFY. MET WITH K. JOHNSON REGARDING MET WITH J. COHEN AND K. JOHNSON REGARDING HEARING.ATTENDED HEARING. COORDINATED WITH MARSHALL'S SERVICEREGARDING INTERVIEW OF K. TRUDEAU. PREPARED FORINTERVIEW OF K. TRUDEAU WITH K. JOHNSON. MET WITH J.COHEN REGARDING SAME. ATTENDED INTERVIEW AT MCC.REVIEWED APPELLATE FILING BY K. TRUDEAU.

12.7

e/19/2013 BRZ

PREPARED FOR STATUS HEARING FOLLOWING K. TRUDEAUINCARCERATION. MET WITH K. JOHNSON

METWITH J. COHEN REGARDING HEARING. CORRESPONDED WITH K.TRUDEAU AND COUNSEL REGARDING FOLLOW-UP INTERVIEW.DRAFTED LETTER TO K. TRUDEAU REGARDING OBLIGATIONS TODISCLOSE ASSETS.

5.4

s/20/2013 BRZ

MET WITH K. JOHNSON IN PREPARATION FOR INTERVIEW WITH K.TRUDEAU. CORRESPONDED WITH K. TRUDEAU AND COUNSELREGARDING INTERVIEW. INTERVIEWED K. TRUDEAU REGARDINGFU RTH ER ASSET DISCLOSURE.

4.8

e/23/2013 BRZ

REVIEWED CORRESPONDENCE FROM FTC REGARDINGRECEIVERSHIP RECOVERY OF ASSETS. TELEPHONE CONFERENCEWITH J. COHEN REGARDING SAME. CONFERRED WITH B. KANEAND K. JOHNSON REGARDING SAME.

7.4

e/24/2013 BRZ

DRAFTED SUBPOENA FOR BANK ACCOUNT RECORDS.CORRESPONDED WITH K. JOHNSON REGARDING K. TRUDEAUINTERVIEW AND RELATED MATTERS. FINALIZED CEASE AND DESISTLETTER TO A. HUSSEIN.

2.6

9/2s/2073 BRZ

PREPARED FOR INTERVIEW WITH K. TRUDEAU, INCLUDING REVIEWOF RELATED DOCUMENTS AND OUTLINE OF ISSUES. MET WITH K.JOHNSON AND J. COHEN IN PREPARATION FOR SAME. TELEPHONECONFERENCE WITH COUNSEL FOR K. TRUDEAU REGARDINGATTENDANCE OF FTC. INTERVIEWED K. TRUDEAU REGARDINGASSET DISCLOSURE.

8.7

e/2s/20L3 ADMIN FINALIZED AUGUST INVOICE FOR LEGAL SERVICES. 1.0


GIN Network Truth (the smart group) INVOICE NO: 1082OCTOBER 7,20L3


Description of Services Rendered

e/26/2073

PREPARED FOR STATUS HEARING, INCLUDING DRAFTING OUTLINEOF PRESENTATION TO COURT. TELEPHONE CALL WITH J. COHENREGARDING SAME. MET WITH K. JOHNSON IN PREPARATION FORHEARING, INCLUDING TELEPHONE CONFERENCE WITH B. KANEAND A. JEN REGARDING SUPPORTING DOCUMENTATION ANDDEVELOPMENTS. ATTENDED COURT HEARING. INVESTIGATEDACCESS TO MIGROS BANK ACCOUNT WITH K. JOHNSON.

9/27/2013

REVIEWED WILLIAM HILL TRANSACTION REPORT. FORWARDEDSAME TO COUNSEL FOR FTC AND K. TRUDEAU. TELEPHONE CALLWITH J. COEHN AND B. KANE REGARDING RECEIVERSHIP ISSUES,INCLUDING EFFECT OF COORDINATING REVIEW OF PREVIOUSDISCOVERY. BEGAN DRAFTING RECEIVER STATEMENT REGARDINGCOERCIVE SANCTIONS. RESEARCHED FACTUAL SUPPORT INCONNECTION WITH EVALUATION OF POSSIBLE USE OF COERCIVESANCTIONS. REVIEWED PROPOSED ORDER ON FTC'S MOTION TOMODIFY RECEIVERSHIP ORDER AND RESPONSE BY K. TRUDEAU.

s/30/2013

TELEPHONE CONFERENCE WITH J. COHEN REGARDING EFFECT OFCOERCIVE SANCTIONS ON RECEIVERSHIP ESTATE ANDIMPLICATIONS OF POSSIBLE FEDERAL GOVERNMENT SHUT-DOWNON HEARING SCHEDULE. REVIEWED AND ANALYZED FTCPLEADI NGS RECOMM ENDING I M POSITION OF COERCIVESANCTIONS. CONFERRED WITH B. KANE AND K. JOHNSONREGARDING SAME. REVIEWED AND ANALYZED EARLIER HEARINGTRANSCRIPT IMPOSING RECEIVERSHIP AND RELATED PLEADINGS INCONNECTION WITH PREPARATION OF RECEIVER'S STATEMENTREGARDING COERCIVE SANCTIONS.

Time and Fee Summary:

Timekeeper Hours Rate Fee ValueBlair R. Tanzig 73.4 S+oo s29,360Admin 1.0 s1s0 Slso



UNITED STATES DISTRICT COURT FOR

THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

FEDERAL TRADE COMMISSION,

Plaintiff,

v.

KEVIN TRUDEAU,

Defendant.

)

)

)

)

)

)

)

)

)

)

Case No.: 03-C-3904

Hon. Robert W. Gettleman

NOTICE OF MOTION

PLEASE TAKE NOTICE that, on Thursday, November 21, 2013, at 1:30 p.m., or as

soon thereafter as counsel may be heard, the undersigned shall appear before the Honorable

Robert W. Gettleman, United States District Court for the Northern District of Illinois, Eastern

Division, or such other judge as may be sitting in his place in Courtroom 1703, 219 S. Dearborn

Street, Chicago, Illinois 60604, and shall present the Receiver’s First Motion for Interim

Approval of Fees and Expenses, a copy of which is hereby served upon you.

Dated: November 15, 2013 Respectfully Submitted,

ROBB EVANS & ASSOCIATES LLC,

RECEIVER

By: /s/ Blair Zanzig

(One of Its Attorneys)

Blair R. Zanzig (No. 6273293)

John F. Hiltz (No.6289744)

Kathy Wantuch (No. 6294034)

HILTZ WANTUCH & ZANZIG LLC

53 West Jackson Blvd., Suite 205

Chicago, Illinois 60604

Telephone: 312.566.9008

Fax: 312.566.9015

Counsel for Robb Evans & Associates, Receiver



CERTIFICATE OF SERVICE

I, Blair R. Zanzig, an attorney, hereby certify that, on the 15th day of November, 2013, I

caused a true and correct copy of the foregoing Notice of Motion to be served via the Court’s

Electronic Case Filing System on the following:

Kimball Richard Anderson

[email protected]

Thomas Lee Kirsch, II

[email protected]

Katherine E. Rohlf

[email protected]

Michael Mora

[email protected]

Jonathan Cohen

[email protected]

Amanda B. Kostner

[email protected]

David O’Toole

[email protected]

/s/ Blair R. Zanzig









Documents

GIN Network Truth (the smart group)docshare01.docshare.tips/files/18516/185163558.pdf · GIN Network Truth (the smart group) 6 15. The Receiver has also reviewed records relating